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by the taxpayer by her signature on the assent form, was a clear
and concise agreement, in written form, delineating the terms
under which the husband would support the taxpayer. The payor-
husband's signature on the letter was not necessary for the
agreement to be valid, as his attorney acted as his agent and the
husband in fact carried out the terms of the agreement.
In contrast to the letter in Azenaro v. Commissioner, supra,
the language of the March 30, 1992, letter is unequivocally that
of a proposal or offer to negotiate. ("If this arrangement is
acceptable * * *.") The March 30, 1992, letter was not signed by
Mrs. Keegan, nor was any other writing acceding to its terms
executed on her behalf. See Estate of Hill v. Commissioner,
supra at 856-857; Harlow v. Commissioner, T.C. Memo. 1984-393 ("A
unilateral written statement by a party stating that he is
willing to pay his spouse certain sums for her support clearly
does not meet the statutory requirement of a written separation
agreement.")
Petitioner next cites Jefferson v. Commissioner, supra, in
support of his contention that "though the letter itself
constituted a proposal, its acceptance made it an enforceable
agreement and a 'written instrument' within the meaning of
section 71." However, Jefferson v. Commissioner, supra, is
distinguishable from the facts of this case. In Jefferson v.
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